Estate of Moyer v. Comm'r
United States Tax Court
1. For many years the Philadelphia-Baltimore Stock Exchange, an unincorporated association, has engaged in the operation of a security exchange. In 1876 the Exchange established a Gratuity Fund. Since its establishment the Gratuity Fund has been maintained exclusively to provide benefits upon the death of members of the Exchange.
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1. For many years the Philadelphia-Baltimore Stock Exchange, an unincorporated association, has engaged in the operation of a security exchange. In 1876 the Exchange established a Gratuity Fund. Since its establishment the Gratuity Fund has been maintained exclusively to provide benefits upon the death of members of the Exchange. Held, that for purposes of Federal income taxation (1) the Exchange and the Gratuity Fund are separate entities, (2) the Gratuity Fund was during the taxable year 1953 a mutual insurance company other than life or marine and taxable under section 207, I.R.C. 1939,…
1Opinion of the Court
Withet, Judge:
The respondent determined deficiencies in tax of the petitioners as follows:
Docket Petitioner No. Kind of tax Year Deficiency
59017 Estate of Clarence L. Moyer, Deceased, C. Leigh Moyer, Jr., Executor, and Lena W. Moyer, Widow of Clarence L. Moyer, Deceased. Income 1950-$1,968.32
69041 Gratuity Fund of Philadelphia-Baltimore Stock Exchange and Trustees of Gratuity Fund. Income 1953-1954-886. 66 4,678.94
71324 Charles B. Barclay and Katharine B. Barclay.. Income 1955-1954-5, 745.59 376.86
71325 Estate of William K. Barclay, Deceased, Charles B. Barclay, Executor. Estate 6,615.35
71378…
2Cases cited9 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Commonwealth v. WetherbeeMassachusetts Supreme Judicial Court · 1870
- Commissioner of Internal Revenue v. TreganowanCourt of Appeals for the Second Circuit · 1950
- Estate of Strauss v. CommissionerUnited States Tax Court · 1949
- Order of R. Employees v. CommissionerUnited States Tax Court · 1943
4 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Theodore v. CommissionerUnited States Tax Court · 1962
- Tighe v. CommissionerUnited States Tax Court · 1959
- A. C. Ross, District Director of Internal Revenue, Atlanta, Georgia v. Suzanne Odom, Individually and as of the Estate of Benton Odom, DeceasedCourt of Appeals for the Fifth Circuit · 1968
- Modern Life & Acci. Ins. Co. v. CommissionerUnited States Tax Court · 1968
- Oklahoma State Union of Farmers Educational & Cooperative Union v. CommissionerUnited States Tax Court · 1977
5 more not listed; retrieve them via the Exa API.